Ayana Dow

We (@fund_defi) submitted a letter in response to the SEC’s RFI asking for thoughts on "exchanges" and crypto ATSs. TL;DR: don't misclassify DeFi technology and devs that aren't actually performing "exchange" functions. We urge the Commission to: 1️⃣ Adopt a functional test for an exchange "facility” so only those actually performing exchange functions are in scope, and not disintermediated software, AMMs, smart contracts, or developers. 2️⃣ Avoid an overly broad reading of a “group of persons" constituting an "exchange." Where there’s no shared intent or control over exchange functions, developers/entities shouldn’t be treated as an exchange just because their software is used by one. Bottom line: DeFi tools that provide liquidity or run autonomously aren’t performing exchange functions and neither the tech nor its devs should be regulated as exchanges. Full letter: sec.gov/files/ctf-writ…

@fund_defi Read the SEC’s RFI here: sec.gov/newsroom/speec…

We (@fund_defi) submitted a letter in response to the SEC’s RFI asking for thoughts on "exchanges" and crypto ATSs. TL;DR: don't misclassify DeFi technology and devs that aren't actually performing "exchange" functions. We urge the Commission to: 1️⃣ Adopt a functional test for an exchange "facility” so only those actually performing exchange functions are in scope, and not disintermediated software, AMMs, smart contracts, or developers. 2️⃣ Avoid an overly broad reading of a “group of persons" constituting an "exchange." Where there’s no shared intent or control over exchange functions, developers/entities shouldn’t be treated as an exchange just because their software is used by one. Bottom line: DeFi tools that provide liquidity or run autonomously aren’t performing exchange functions and neither the tech nor its devs should be regulated as exchanges. Full letter: sec.gov/files/ctf-writ…

The brilly @_ayanadow chatted with @Yuschukid for a @block_stories spotlight on the @CFTC’s no-action letter for @phantom, unpacking what it signals for DeFi, more broadly!

Another big win for @Uniswap and @haydenzadams today. The court dismissed all claims in the Risley class action with prejudice, reaffirming the core principle that a developer isn’t liable for third-party misconduct simply because it built neutral infrastructure others used to do bad things. Read the whole opinion here courtlistener.com/docket/6321327…

The right result. Congrats to @Uniswap and the team at @gibsondunn for putting this one to rest (with appreciation to @WilmerHale for repping @SolanaInstitute and @fund_defi in our amicus efforts).

Today, SPI together with @fund_defi, submitted a letter to Commissioner @HesterPeirce and the @SECGov Crypto Task Force providing context on non-custodial wallets and neutral user interfaces. Recent submissions have inadvertently conflated different technologies and overlooked key legal precedents. Our letter aims to ensure policymakers have accurate information as they develop a coherent regulatory framework. Read the full submission: solanapolicyinstitute.org/legal-archives…

[NEW] Today, the DEF team published a myth vs. fact resource on the Blockchain Regulatory Certainty Act The BRCA is good policy, and its inclusion in market structure is a red line for the industry for good reason. Below: we debunk common misconceptions about the BRCA. 👇

4/ Effective regulation must recognize the real differences between CeFi and DeFi technologies, avoid entrenching particular technical solutions, and ensure rules are workable in practice. Read our full comment letter here: defieducationfund.org/docs/executive…

3/ Our comment letter requests that the FTC remove Count One or significantly revise it to avoid mandating specific technical architectures. We highlight that using “unfairness” authority to impose specific technical requirements turns the FTC into a de facto standard-setting body for engineering controls, without statutory authority. Importantly, Congress is actively working on comprehensive digital asset legislation. The FTC should not preempt these legislative efforts through enforcement settlements.

1/ @fund_defi joined @BlockchainAssn, @crypto_council, and @SolanaInstitute in submitting comments to the @FTC on its proposed order related to Nomad/Illusory Systems Inc. While we share the FTC’s consumer protection goals, the proposed order suggests that crypto systems must use "circuit breakers" and "kill switches" – calling this a "widely-accepted industry norm." Why it matters: Not all crypto systems are designed the same way, and mandating technical solutions such as centralized controls would stifle DeFi innovation.

2025 was a massive year for crypto in Washington. In our latest @fund_defi blog, we unpack the years' biggest crypto policy victories, and the real obstacles that remain for DeFi developers. In 2026, it is imperative that we hold the line where it matters most. As we design rules for the next century, we can’t afford to recreate the failures of the systems we’re trying to evolve beyond. Satoshi didn’t invent Bitcoin so we could copy-paste Wall Street gatekeepers into Web3 and call it “compliance.” Bitcoin and DeFi were born as a response to the perils of traditional finance. In 2026, @fund_defi will be there to protect self-custody and ensure that DeFi developers can continue to build without the fear of misapplication of intermediary-suited frameworks. The beauty of DeFi is the fact that it is permissionless, intermediary-less, and outside of the control of gatekeepers and legacy overlords. As we advance frameworks to regulate the future of this industry, it is essential that robust developer protections remain at the forefront of crypto policy efforts.

1/ Citadel got DeFi wrong. Today, DEF, @a16z, @DigitalChamber, @orca_so, @theblockprof, & @UniswapFND wrote to @SECGov in response to @citsecurities' letter misrepresenting how DeFi technology works. Why this group? Citadel blatantly miscited us, and we feel obligated to correct the record.

5/ We’re grateful to the @CFTC, and to Acting Chairman Caroline Pham for her leadership, for opening the door to public engagement. Opportunities like this are essential for building thoughtful, collaborative, and forward-looking U.S. digital asset policy. You can read the full letter here: defieducationfund.org/docs/executive….

4/ We also highlight that blockchain-based derivatives can operate within a transparent, compliant framework, but only if regulators provide clarity that supports responsible innovation rather than stifling it.

CFTC Chairman Nomination Hearing @SenateAgGOP: @michaelselig just told Congress what the industry’s been saying for years: blockchain isn’t one-size-fits-all — and truly decentralized, onchain tech shouldn’t be forced into legacy intermediary rules. DeFi future looking bright here in America. Thank you @michaelselig and @JohnBoozman for your tireless work for the American people. @JohnBoozman: "As the committee deliberates granting the CFTC spot digital regulatory authority. How should we think about DeFi and ensuring that activities with respect to technology are not subject to inappropriate intermediary registration regimes?" @michaelselig : "Thank you, Senator. As I mentioned, I think there is this issue of regulation-by-enforcement, and sometimes we take a one-size-fits-all approach to all types of financial products and services. But really, Blockchain enables such a broad swath of new types of products, services, applications, and so it may not make sense in many cases to apply financial regulation, for example, to a video game app that runs on a blockchain." "So I think when we're thinking about DeFi, it's something of a buzzword, but really we should be looking to onchain markets and onchain applications, and thinking about the features of these applications, as well as where there's an actual intermediary involved, where we have some operator, administrator, and in many cases, that may not be and so we have to think about the best approach, and I look forward to working with your office to figure that out."

Incredible revelation by the SDNY in its response to @rstormsf. Apparently, users don’t execute their own transactions whatsoever; instead, they assert that the Tornado Cash UI itself conducts the transaction and the user’s wallet is merely a tool for it to do so. In other words, according to the SDNY, the UI is sentient and users are instruments of its doings. Folks, we’ve reached AGI. This completely ignores the reality that users control their own assets and execute their own transactions with their private key. And worse, it was confidently submitted to an American court room in opposition to a man’s freedom. So after years of preparing for this case—including studying for trial, listening to hours of testimony, and questioning experts—this is the best the SDNY has to offer. Either the SDNY doesn’t get it or is intentionally misunderstanding the facts.

Today, @fund_defi and @SolanaInstitute filed an amicus brief in an important patent lawsuit supporting @Uniswap & @UniswapFND. As we explain, the asserted patents do not reflect real breakthroughs. They claim abstract ideas applied to new technology. That risks discouraging real innovation. Read more: defieducationfund.org/post/def-files…